Climate Policy Engagement Analysis
Climate Policy Engagement Overview: Dow, Inc. (Dow) exhibits policy engagement that is broadly misaligned with policy pathways for delivering the temperature goals of the Paris Agreement. Although the company’s top-line messaging is broadly positive, it actively engages on climate policy in the EU and US with mostly negative positions, particularly on matters related to the energy transition and greenhouse gas (GHG) emissions regulation. Dow holds board memberships to industry associations that continue to obstruct climate policy, including as the US Chamber of Commerce and National Association of Manufacturers.
Top-line Messaging on Climate Policy: Dow’s top-line messaging on climate policy is broadly positive. On the “Climate & Carbon Policy” section of its website, which does not appear to have been updated since at least 2022, l, Dow states support for market-based carbon pricing through emissions trading. In the same webpage, and again in its 2024 Progress Report from February 2025, the company states support for the Paris Agreement and GHG emissions reductions in line with the 1.5°C target.
Engagement with Climate-Related Policy: Dow appears to engage on specific climate-related policies with a mix of positive and negative positions. In its 2023 CDP Response, Dow expressed support for a market-based approach to carbon pricing through a voluntary emissions trading system (ETS), stating that such a system “would achieve greater carbon reduction for less cost than a clean-energy standard approach,” indicating a preference for this mechanism over other forms of government regulation. More positively, in the same CDP response, Dow stated support for Extended Producer Responsibility (EPR) legislation, highlighting its advocacy in California on the Plastic Pollution Prevention and Packaging Producer Responsibility Act. Additionally, in its 2024 Progress Report the company supported circular economy policies, stating that it supports “the transition to reusability or recyclability.” However, in an interview published bySustainability Magazine in January 2025, the company appeared to advocate for a narrow scope of the UN Global Plastics Treaty. At the federal level in the US, Dow submitted oppositional August 2023 comments on the Biden administration’s power plant carbon standards, stating that “the EPA continues to take an aggressive approach towards tightening regulations with regulatory changes that are not based on the best available science and in some cases are not technically feasible.”
Positioning on Energy Transition: Dow takes mostly negative positions on the transition of the energy mix. In a February 2025 joint letter to the US Congress, Dow advocated for policymakers to maintain the Inflation Reduction Act (IRA)'s clean hydrogen tax credit, however while emphasizing a prominent role for fossil gas as a feedstock for eligible hydrogen production. This echoes Dow’s February 2024 comments on the Biden administration’s proposed implementation of the IRA hydrogen tax credit, in which the company opposed several aspects of the policy that were designed to incentivize the transition away from fossil fuel-based hydrogen feedstocks, including by advocating for changes to the hydrogen production lifecycle greenhouse gas emissions rate model. At the state level, a May 2024 press release highlighted the company’s efforts to prolong the role of fossil fuels in the energy mix through its partnership with Wyoming State government and the University of Wyoming on the Wyoming Gas Injection Initiative (WGII), which aims to “enhance oil well productivity” and “revitalize” existing oil fields. In August 2023 comments on the Biden administration’s proposed power plant rules, Dow supported a continued role for fossil gas in the energy mix, stating that “natural gas connected to carbon sequestration (CCUS) will be required for the energy transition,” while also appearing to advocate for delayed targets for emissions reduction compliance. . In its quarterly Federal Lobbying Disclosure filed in Q2 2024, the company discloses advocacy on policies such as the Lower Energy Costs Act (H.R. 1), the Nuclear Fuel Security Act (H.R. 5718) and the Hydrogen for Industry Act (S. 646), but did not specify its positions. Additionally, in the same disclosures, the company also appeared to engage on policy topics related to the energy transition, including permitting reform and small nuclear technology, “renewable energy matters” and plastics to fuel.
Industry Association Governance: Dow discloses a list of industry association memberships on its website, but without detail of the groups’ policy positions or advocacy activities. Dow is a board member of several member industry associations that engage negatively on climate policy, including the American Fuel & Petrochemical Manufacturers (AFPM), the US Chamber of Commerce, and the German Chemical Industry Association (VCI) as well as the European Chemical Industry Council (CEFIC), where the President of Dow Europe sits on the Executive Committee and serves as the Chair of the Climate Change & Energy Council.
A detailed assessment of the company's corporate review on climate policy engagement can be found on InfluenceMap's CA100+ Investor Hub here.
InfluenceMap collects and assesses evidence of corporate climate policy engagement on a weekly basis, depending on the availability of information from each specific data source (for more information see our methodology). While this analysis flows through to the company’s scores each week, the summary above is updated periodically. This summary was last updated in Q3 2025.